SEFA
           United States
           Environmental Protection
           Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 2771 f
EPA-450/3-85-019b
 December 1986
           Air
Surface  Coating     Final
Of Plastic Parts     EIS
For Business
Machines—
Background
Information for
Promulgated  Standards

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                                   NOTICE

This document has not been  formally  released by EPA and should not now be
construed to represent Agency  policy.   It  is being circulated for comment
on its technical accuracy and  policy implications.
          SURFACE COATING OF PLASTIC PARTS FOR  BUSINESS MACHINES-
              BACKGROUND INFORMATION FOR PROMULGATED STANDARDS
                Emission Standards  and  Engineering Division
                   U.  S.  Environmental Protection Agency
                       Office of Air and Radiation
               Office of Air Quality  Planning  and  Standards
              Research Triangle Park, North Carolina  27711

                               December 1986
                                          U S. Environmental Protection Agency
                                          Region 5, Library (PL-12J)
                                          77 West Jackson Boulevard, 12tn Moor
                                          Chicago, IL  60604-3590

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                       ENVIRONMENTAL PROTECTION AGENCY

                           Background Information
                                  and Final
                       Environmental Impact Statement
       for the Surface Coating of Plastic Parts for Business Machines

                                Prepared by:
 Jack R.  Farmer                                              (Date)
 Director,  Emission Standards  and  Engineering Division
 U.  S. Environmental Protection  Agency
 Research Triangle  Park,  N.C.  27711

 1.   The  promulgated standards of  performance would limit emissions  of
     volatile organic compounds  (VOC's)  from new,  modified,  and
     reconstructed  facilities  that surface  coat  plastic parts  for business
     machines.  Section 111 of the Clean Air Act (42 U.S.C.  7411), as
     amended, directs the Administrator  to  establish standards of
     performance for any  category  of new stationary source of  air pollution
     that ". .  . causes or contributes significantly to air  pollution  which
     may  reasonably be anticipated to  endanger public health or welfare."

 2.   Copies of  this document have  been sent to the following Federal
     Departments:   Labor, Health and Human  Services,  Defense,
     Transportation,  Agriculture,  Commerce,  Interior,  and Energy;  the
     National Science Foundation;  the  Council  on Environmental  Quality;
     State and  Territorial Air Pollution Program Administrators;  EPA
     Regional Administrators; Local Air Pollution  Control  Officials; Office
     of Management  and Budget; and other interested parties.

 3.   The  comment period for review of  this  document  is  75 days  from the
     date of publication of the proposed standard  in the  Federal Register.
     Mr.  C. Douglas Bell may be contacted at  (919) 541-55/8  regarding the
     date of the comment period.

4.   For  additional information contact:

    Ms.  Laura Butler or Mr. Doug Bell
    Standards Development Branch (MD-13)
    U. S. Environmental Protection Agency
    Research Triangle Park, N.C.  27/11
    Telephone:   (919) 541-5578

5.  Copies of this document may  be obtained from:

    U. S. EPA Library (MD-35)
    Research Triangle Park, N.C.  27711
    Telephone:   (919) 541-2777

    National  Technical  Information Service
    5285 Port Royal Road
    Springfield,  Va.  22161
                                    11

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                             TABLE OF CONTENTS
 Section                                                              Page

 1   SUMMARY	    1-1

    1.1   Summary of  Changes Since  Proposal	    1-1
    1.2   Summary of  Impacts of  Promulgated Action	    1-2
         1.2.1   Alternatives  to Promulgated Action	    1-2
         1.2.2   Environmental Impacts  of  Promulgated Action	    1-2
         1.2.3   Energy  and Economic  Impacts of the
                Promulgated Action	    1-3
         1.2.4   Other Considerations	    1-3
                1.2.4.1   Irreversible  and Irretrievable
                         Commitment of Resources	    1-3
                1.2.4.2   Environmental and Energy Impacts
                         of Delayed Standards	    1-3

 2  SUMMARY OF PUBLIC COMMENTS	    2-1

   2.1   Standards and Affected  Facility	    2-1
   2.2   Achievability of the Standard	    2-3
         2.2.1   Availability of  Compliance Coatings	    2-3
         2.2.2   Availability of  Primers for Waterborne Coatings	   2-4
   2.3   Recordkeeping and Reporting Requirements	   2-4
         2.3.1   Recordkeeping and Reporting Requirements	   2-4
         2.3.2   Sample Size for Method 24	   2-6
   2.4   Emission Control Technology	   2-7
   2.5   Economic Impact	   2-8
   2.6   EMI/RFI Shielding	   2-8
   2.7   References for Chapter 2	   2-9
                              LIST OF TABLES
Table                                                                Page

2-1       List of Commenters on Proposed Standards of Performance
          for Surface Coating of Plastic Parts for Business
          Mach i nes	    2-2

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                                 1.   SUMMARY

      On January 8, 1986, the Environmental Protection Agency (EPA)
 proposed new source performance standards (NSPS) for surface coating of
 plastic parts for business machines (51 FR 866) under authority of
 Section 111 of the Clean Air Act.  Public comments were requested in the
 proposal in the Federal Register.  A total of three comments from
 industry, one from a trade association, and one from a State agency were
 submitted during the comment period.  The comments that were submitted,
 along with responses to these comments, are summarized in this document.
 The summary of comments and responses serves as the basis for the
 revisions made to the standards between proposal and promulgation.
 1.1  SUMMARY OF CHANGES SINCE PROPOSAL
      In response to the public comments and as  a result of EPA
 reevaluation,  certain changes have  been made in the proposed standards.
 The more significant  changes are summarized below.
      Section 60.721,  Definitions, has  been amended  by the addition of a
 definition for the  term "coating operation."  The addition of this
 definition will  clarify the  compliance provisions of the regulation for
 situations where two  or more types  of  coatings  are  applied at different
 times at  the same spray booth.
     Also  in Section  60.721,  the meaning of  the  symbol  "T"  used in the
 equations  to determine  compliance was  revised to  be  the  transfer
 efficiency for each type of  coating  application equipment  used at a
 coating operation.  A symbol  "Tavq"  was added to  represent  the volume-
 weighted average transfer efficiency for a coating operation to ensure
 that the distinction  is clear between  transfer efficiency  and average
transfer efficiency in  equations presented later  in the regulation.
                                    1-1

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      Section 60.722, Standards for volatile organic compounds (VOC's), has
 been clarified to state specifically that all VOC emissions that are
 caused by coatings applied in each affected facility, regardless of the
 actual point of discharge of those emissions into the atmosphere, are
 covered by the standard and must be included when compliance with the
 numerical emission limits is determined.  Refer to Chapter 2, Section 2.1,
 Standards and affected facility, for further explanation of the change.
      In Section 60.723, Performance tests and compliance provisions,
 Table 1 has been revised to clarify the applicability of the transfer
 efficiency (TE) values.  Table 1 now specifies the TE's for each type of
 application equipment for specific types of coatings (i.e., prime,  color,
 texture, fog, and touch-up).   This change was made because air-assisted
 airless and electrostatic spray guns have not been used to apply texture,
 touch-up, or fog coats.  Therefore, the TE's presented in Table 1 at
 proposal were not applicable  to these types of operations.  However, if an
 owner or operator can demonstrate to the satisfaction of the Administrator
 that TE's other than those presented in Table 1  are appropriate,  the
 Administrator will  approve their use on a case-by-case basis.   The  TE
 values for application methods  not listed in Table 1  shall also be
 approved by the Administrator on a case-by-case  basis.
 1.2  SUMMARY OF IMPACTS OF PROMULGATED  ACTION
 1.2.1   Alternatives  to Promulgated Action
      The regulatory  alternatives  are  discussed in  Chapter  6 of Volume  I of
 the background  information document (BID)  for the  proposed standards
 (EPA-450/3-85-019a).   These regulatory  alternatives reflect the different
 levels  of emission control, one of which  is  selected that  represents best
 demonstrated  technology (BDT), considering costs,  nonair quality health,
 and environmental and  economic impacts  for facilities that  surface coat
 plastic parts used in  business machines.
 1.2.2  Environmental Impacts of Promulgated Action
     The environmental  impacts are discussed  in Chapter 7 and Appendix D
 of  the Volume I BID.  These impacts have remained unchanged since
 proposal.  The changes  that have been made to the regulation are not of
 sufficient magnitude to affect the environmental impact analysis.
Therefore, the Volume I BID now becomes the final Environmental Impact
Statement for the promulgated standards.

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 1.2.3  Energy and Economic Impacts of the Promulgated Action
      The energy impacts of the proposed standards were evaluated in
 Chapter 7 of the Volume I BID.  It was determined that the control
 technologies that are the basis for the regulatory alternatives have a
 negligible effect on the energy requirements  for  facilities that surface
 coat plastic parts for business machines.  Therefore,  a negligible  energy
 impact is attributed to the proposed or final  standards.
      The economic impacts of the proposed  standards were  evaluated  in
 Chapter 9 of the Volume I BID.   Since proposal, no changes  have been made
 to  the economic analysis.  The nationwide  cost in the  fifth year of
 implementation  is projected to be a net credit.
 1.2.4  Other Considerations
      1.2.4.1 Irreversible and  Irretrievable Commitment of  Resources.  The
 Volume I  BID concluded  in Chapter 7  that for many of the  regulatory
 alternatives, additional  equipment will be required.  However,  consumption
 of  steel  and other raw materials  for  this purpose  will be small compared
 to  the national usage of  each material.
      1.2.4.2 Environmental and Energy  Impacts of  Delayed Standards.
Delay  in  the standards would cause a  similar delay in realizing the
beneficial impacts associated with the standards.   No changes in the
potential effects of delaying the standards have occurred since proposal
of the standards.
                                   1-3

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                       2.  SUMMARY OF PUBLIC COMMENTS

      A list of commenters, their affiliations, and the EPA docket entry
 number assigned to each comment is shown in Table 2-1.  Five letters
 containing comments on the proposed standards for the surface coating of
 plastic parts for business machines industry were received.   Significant
 comments have been organized into the following six categories:
      1.  Standards and Affected Facility;
      2.  Achievability of the Standards;
      3.  Recordkeeping and Reporting Requirements;
      4.  Emission Control  Technology;
      5.  Economic Impact;  and
      6.  Electromagnetic Interference/Radio Frequency Interference
 (EMI/RFI)  Shielding.
 The comments  and  the  issues  they  address are discussed in  the  following
 sections  of this  chapter.
 2.1   STANDARDS AND AFFECTED  FACILITY
      Comment;  One commenter (IV-D-4) stated that because  the  affected
 facility  is the spray  booth,  the  standards  for VOC emissions set forth in
 Section 60.722 could be  interpreted  as applying only  to those  VOC's
 emitted from the  spray booth.  The effect of this interpretation would be
 to exclude VOC's that are emitted from outside the spray booth  (i.e.,
 flash-off area and oven) from the coverage of the standards.  To rectify
 this problem, the commenter  suggested that VOC emission limits be
established for the entire line (i.e., spray booth, flash-off area,  and
oven)  but that the reconstruction provisions still apply only to the spray
booth.
                                    2-1

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           TABLE 2-1.   LIST OF COMMENTERS ON  PROPOSED STANDARDS OF
        PERFORMANCE FOR PLASTIC  PARTS FOR BUSINESS MACHINES  INDUSTRY3


 Docket item No.               Commenter/affiliation


 IV-D-1                       Mr.  Robert K. Brothers
                              Director, Regulatory Affairs
                              Eastman Kodak Company
                              343  State Street
                              Rochester, New  York  14650

 IV-D-2                      Mr.  Ryan Sullivan
                              Research and Development Associate
                             The  B. F. Goodrich Company
                             Electronic Chemicals Department
                             9221 Brecksville Road
                             Brecksville, Ohio  44141

 IV-D-3                      Ms.  Ellen Robinson
                             Staff Director
                             The  Society of  the Plastics Industry, Inc.
                             Structural Foam Division
                             355  Lexington Avenue
                             New  York, New York 10017

 IV-D-4                       Mr.  Charles M.  Taylor
                             Chief, Division of Air Pollution Control
                             State of Ohio Environmental Protection Agency
                             361  East Broad Street
                             Columbus, Ohio  43266-0149

 IV-D-5                       Mr.  Ryan Sullivan
                             Research and Development Associate
                             The  B. F.  Goodrich Company
                             Electronic Chemicals Department
                             9921 Brecksville Road
                             Brecksville,  Ohio  44141


aThe docket No. for this project  is A-83-50.   Dockets are on file at  EPA
 Central Docket Section in Washington,  D.C.  and at the Office of Air
 Quality Planning and Standards in Durham,  N.C.
                                  2-2

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      Response:  The EPA believes that the wording of the proposed
 standards precludes the interpretation suggested by the commenter and,
 therefore, believes it to be unnecessary to  implement the commenter's
 solution.  Section 60.722 uses the language  "no affected facility shall
 cause the discharge into the atmosphere" (emphasis added).  The coatings
 application which takes place in the spray booth is clearly the cause of
 VOC emissions from the flash-off area and oven.  Therefore, VOC emissions
 from these areas are covered by the standards.
      To protect against possible misinterpretation, Section 60.722 has
 been revised by the addition of the following:
         (b)  All VOC emissions that are caused by coatings applied in each
      affected facility, regardless of the actual point of discharge of
      emissions Into the atmosphere, shall be included in determining
      compliance with the emission limits in (a) above.
      The language of Section 60.723 also precludes the commenter's
 interpretation.   The calculations by which performance is determined
 include all VOC's resulting from coatings applied in the spray booth  and
 do not  allow for the exclusion of VOC's that may be emitted from the
 flash-off area and oven.   It should be noted that because the affected
 facility remains unchanged,  the reconstruction provisions still  apply only
 to the  spray booth.
 2.2  ACHIEVABILITY OF THE  STANDARDS
 2.2.1  Availability of Compliance Coatings
      Comment:  One commenter (IV-D-3)  stated  that  "conformance coatings"
 (i.e.,  coatings  that comply  with  the  standards)  cannot achieve performance
 levels  for  abrasion,  adhesion,  and  chemical resistance.  Another commenter
 (IV-D-1)  stated  that "compliance  coatings" (high-solids,  solvent-based and
waterborne  coatings) could not meet performance  specifications (i.e.,
chemical  and stain resistance) for  certain business machine uses.  The
commenter suggested  that the regulation allow variances on a case-by-case
basis if  the coater  can demonstrate to the satisfaction of the
Administrator that no coating exists that meets both the emission limits
and necessary performance specifications.
     Response:  The commenters were contacted for information  on the
specific cases for which they stated that compliance coatings  could not
                                    2-3

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                                         1 -1*
 meet certain performance specifications.     However, no information was
 provided that would clarify the specific situations mentioned by the
 commenters.
      The EPA has determined that high-solids, solvent-based and waterborne
 coatings that comply with the emission limits when used with appropriate
 coating application technologies are being used for prime,  color, texture,
 and touch-up coats by coaters in at least two States.5'6  These coatings
 have been approved by some original equipment manufacturers (OEM's) for
 performance specifications including abrasion, adhesion, and chemical  and
 physical stain resistance. '   The EPA expects coaters to use high-solids,
 solvent-based coatings to achieve compliance and has determined that these
 coatings are available for use. '   Waterborne coatings also can be used
 to meet the standards and are available for use.5'6  For the reasons
 presented above, EPA has determined that the standards are  achievable  and
 has not revised the proposed standards.
 2.2.2  Availability of Primers for Waterborne Coatings
      Comment:   One commenter (IV-D-3)  stated that none of the primers
 available for  waterborne coatings will  achieve the standards.
      Response;   Discussions  with  several coaters,  coating manufacturers,
 and a regional  air quality management district representative affirmed
 that primers that will  achieve the standards are  available  for use with
 waterborne  coatings.   Two coaters  stated that they are using waterborne
 coatings  for primers  and,  in addition,  that  these  waterborne coatings can
 be  applied  as a  combination  primer/barrier coat for certain types of
 plastic that are sensitive to  direct application of solvent-based
 coatings.  '   Two  coating manufacturers are  producing  waterborne primer
 coatings.8'9 A  regional  air quality management district  representative
 also stated  that waterborne primers are available that will  achieve the
 standards and are  being used 1n production.   He noted that,  in many
cases, waterborne  coatings are not used as primers but are  applied as a
color coat to the  part(s) without the use of  a primer coating.
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  2.3  RECORDKEEPING  AND  REPORTING  REQUIREMENTS
  2.3.1  Recordkeepinq and Reporting  Requirements
       Comment:  One  commenter  (IV-D-1)  stated  that  recordkeeping
  requirements to determine compliance are excessive, particularly for  large
  surface coating operations that coat both plastic  and metal parts with a
  variety of coatings.  The commenter also stated that the cost of analyzing
  coatings using EPA  Reference Method 24 could  be unreasonable.  He
  requested that the  language of the  standards  be changed to allow alternate
  methods of compliance on a case-by-case basis for  facilities that use a
  large number of paint formulations.  One such method suggested by the
  commenter would allow small volume  coatings to be  grouped with a large
  volume coating having similar formulation and application characteristics,
 with the large volume coating required to comprise 90 percent of the total
 coating volume.  The costs of monthly compliance testing would be reduced
 because it would be necessary only  to test the large volume coating
 formulation and to measure the total coatings volume.
      Response:   The level of effort necessary for recordkeeping is  not
 considered excessive.   Most coaters maintain at least some of the infor-
 mation that would be required by these standards,  and some coaters  are
 already maintaining the information needed to perform the calculations to
 determine  compliance with the standards.   This information is available
 from the operation and  inventory logs kept by the  coaters.   In addition,
 the  recordkeeping  requirements,  as written,  are the only feasible way  for
 a coater to demonstrate  continuous monthly compliance with  the
 standards.   The time and costs necessary  to  determine compliance have
 previously  been evaluated by  EPA and were  determined to  be  reasonable.
      In  most cases,  coating composition data determined  by  EPA Reference
 Method 24 can be obtained from the coating manufacturer.  The  coater can
 use  these data  and plant records of  VOC used for dilution to perform the
 calculations necessary to demonstrate monthly  performance.  The EPA
 recognizes that there are rare cases for which the  coater cannot obtain
 EPA  Reference Method 24  data from  an outside coating manufacturer.
 Examples of such cases occur when  coaters manufacture coatings in-house or
modify the formulation (e.g., tinting) of a purchased coating.  The
estimated cost to the coater to perform EPA Reference Method 24 is
$200 per coating.  The EPA considers this cost to be reasonable.

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      Because the time and costs necessary to perform the compliance
 calculations were determined to be reasonable and because EPA Reference
 Method 24 coating composition data can, in most cases, be obtained from
 the coating manufacturer, EPA has determined that the recordkeeping and
 reporting requirements of the standards are not excessive.  Therefore, it
 is unnecessary to implement the commenter's suggested method of compliance
 determination.
 2.3.2  Sample Size for Method 24
      Comment;  One commenter (IV-D-1) stated that the 1-liter sample size
 requested for the determination of VOC content of each coating using EPA
 Reference Method 24 is unreasonable,  especially in the case of specialty
 coatings.  The commenter said that 1  liter  may be equivalent to the total
 volume of coating manufactured or supplied  for a specialty coating,
 whereas EPA Reference Method 24 requires only a 10-gram sample size.   The
 commenter noted that the cost of manufacturing or purchasing additional
 paint  for sample analysis alone would be unreasonable.   The commenter
 recommended that the standards be rewritten to specify a sample size  of
 10 grams.
     Response:   The  sample size was set at  1 liter for several  reasons:
 (1)  losses  of the sample could occur  during transfer of the sample  between
 pieces  of equipment  or sample container and equipment,  (2)  losses of  the
 sample  could  occur during equipment setup,  and  (3)  additional  runs  of the
 EPA  Reference Method 24  tests could require additional  sample  in the  event
 of problems with the initial  runs.  Therefore,  to  account for  any sample
 losses  and for  the need  for  additional  test  runs,  the  sample size remains
 at 1 liter.
     Additionally, the low-volume usage  of  specialty coatings  is expected
 to be a rare  occurrence.   It  should be noted that  if coaters run the  EPA
 Reference Method 24  test,  they are  free  to use as  small a volume as
 necessary to  conduct  the  test.  However, the 1-liter sample size require-
ment would apply when a coating sample is requested for analysis by EPA.
2.4  EMISSION CONTROL TECHNOLOGY
     Comment:  One commenter  (IV-D-4) requested additional information on
control techniques and cost effectiveness of add-on controls for the
                                    2-6

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 oven.   In further discussion with the commenter to clarify his submittal,
 he stated that  in many cases, the State of Ohio requires that emissions
 from new ovens  be controlled with best available technology  (i.e., an
 incinerator), yet the standard does not give credit for the  emission
 reduction achieved through the use of add-on control devices.
      The commenter also stated that there was no discussion  on techniques
 to increase the VOC concentration and to reduce the volumetric flow rate
 of the exhaust gases from the spray booth and the oven (e.g., recircu-
 Tation systems).  He noted that these factors could affect the cost
 effectiveness of any vapor control technologies.
      Response:  The EPA evaluated incineration as a vapor control
 technology for the spray booth, flash-off areas, and oven for a medium-
 size typical surface coating facility.12*13  Total  coating consumption for
 this model  plant was estimated to be 155,000 liters per year with total
 VOC emissions of 85 megagrams (Mg) per year.   The cost-effectiveness  value
 for vapor control of the oven and flash-off areas was estimated to be
 $3,380/Mg of VOC controlled.12   The cost-effectiveness values for vapor
 control  of  the spray booth were estimated to  range  from $10,700/Mg of VOC
 controlled  to $20,620/Mg of VOC controlled, depending on the  spray booth
 ventilation  rate.    Spray booth and oven exhaust air recirculation
 systems  were not examined in this analysis.
     The EPA believes that the  costs of add-on control  devices will result
 in few,  if any,  coaters  selecting such devices to control VOC emissions
 from facilities  that  coat  plastic parts for business machines.  However,
 the compliance provisions  in Section 60.723(b)(2)(iv) are written  to allow
 an owner or  operator  to use add-on controls in order to reduce VOC
 emissions to within the  limits of the standard.  If add-on controls are
 used, the owner  or operator must  demonstrate that the volume-weighted
 average mass of  VOC's emitted to  the atmosphere during  each nominal
 1-month period per unit-volume of coating solids applied (N)  is within the
 limits given in Section 60.722 of the standards because of this equipment
 in order to demonstrate compliance.  In such cases,  compliance would be
determined by the Administrator on a case-by-case basis.
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 2.5  ECONOMIC IMPACT
      Comment:  One commenter (IV-0-3) said that because compliance
 coatings that will meet all performance specifications are not available,
 the proposed standards would force OEM's to change to solid wall plastics
 that can have molded-in color, thereby eliminating structural  foam and all
 coatings and severely impacting both industries, or to move tooling,
 molding, and finishing operations offshore, which would result in
 additional  loss of jobs in the already depressed business machine
 cabinetry market as well as loss of local, State, and Federal  tax
 revenues.
      Response:   The commenter was contacted for clarification  of areas
 where compliance coatings would not meet the performance specifications,
 and EPA was referred to an industry contact.1   No specific information to
 support the comment was given by the contact or by a suggested third
       ,  1<*  1 5
 contact.  *
      Several  coaters and coating manufacturers  have affirmed that both
 waterborne  and  high-solids solvent-based coatings that  could meet the
                                                        fl  Q
 standards are available and are being used by industry.  *   In addition,
 EPA has performed an economic market analysis,  presented  in Chapter  9  of
 the Volume  I  BID for this  industry,  that indicates  that the net effect
 from the  use  of  the combination of  the BDT coatings  and coating
 application equipment is  a net  credit to industry of $30 million/yr.
 Therefore,  because  BOT coatings are  available and are being used  and,
 because there is  a  net credit from  the use  of BDT coatings, no  adverse
 economic  impacts  are  expected.
 2.6  EMI/RFI SHIELDING
     Comment:  One  commenter  (IV-D-2,  IV-D-5) stated that there should be
 an EMI/RFI  shielding  standard and that the  basis of  this standard should
 be a waterborne EMI/RFI shielding coating.  The commenter noted that the
 proposed exemption of  shielding coatings from the regulation provides no
motivation  to maintain  the momentum toward  lower VOC emissions without an
 increase  in the cost of coating operations.  He suggested that the
 standard be  revised to  give credit to coaters using waterborne shielding
coatings instead of solvent-based shielding coatings.
                                    2-8

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      Response:  The waterborne EMI/RFI shielding coating referred to by

 the commenter was not available during development of the standards.  The
 coating is presently undergoing production trials in some areas of the
 country but cannot be considered a demonstrated shielding coating at this
 time. *16  At the 4-year review of the standard, EPA will reevaluate the

 need and technological bases for a standard for VOC emissions from EMI/RFI
 shielding.

 2.7  REFERENCES FOR CHAPTER 2

  1.  Telecon.  Larson, J., MRI, with Robinson, E.,  The Society of the
      Plastics Industry, Inc.  April 10, 1986.  Discussion about comments
      submitted by Ms.  Robinson.

  2.  Telecon.  Larson, J., MRI, with Simmons, I.,  Eastman Kodak Company.
      April 8, 1986.   Discussion about comments submitted by Mr. Brothers.

  3.  Telecon.  Larson, J., MRI, with Simmons, I.,  Eastman Kodak Company.
      June  5 and 17,  1986.   Discussion about coatings usage,  coating  test
      results, and  plant operations.

  4.  Telecon.  Larson, J., MRI, with Simmons, I., Eastman Kodak Company.
      August 5,  19,  and 22, 1986.   Discussion about  coatings  usage.

  5.  Telecon.  Larson,  J., MRI, with Kyle,  H., Hewlett-Packard.  April 15,
      1986.   Discussion about coatings usage and application  techniques.

 6.  Telecon.   Larson,  J.,  MRI, with Guthrie,  J., Bay Area Air  Quality
      Management District.   April  11,  1986.   Discussion about coatings
      usage  in the district.

 7.   Telecon.   Larson,  J.,  MRI, with  McDonald,  C., Foam  Molding Company.
     April  15,  1986.   Discussion  about  coatings usage and application
      techniques.

 8.  Telecon.  Larson, J.,  MRI, with  Edwards,  F., Breakthrough Coatings
     Company.  April 15, 1986.  Discussion  about coatings manufactured by
     the company.

 9.  Telecon.  Larson, J., MRI, with Adams, G., Cardinal Industrial
     Finishes.  April 9, 1986.  Discussion  about coatings manufactured by
     the company.
10.  Docket Item No.
(Supporting Statement for Standard  Form 83.).
11.  Telecon.  Larson, J., MRI, Butler, L., EPA:SDB, and Salman, D.,
     EPA:CPB, with Juris, W., State of Ohio Environmental Protection
     Agency.  April 16, 1986.  Clarification of comments on proposed  NSPS.
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12.  Memorandum from Larson, J., MRI, to Plastic Parts project file.
     November 15, 1985.  Cost-effectiveness calculations for the control
     of VOC emissions from flash-off areas and ovens used in the surface
     coating of plastic parts used in business machines.

13.  Memorandum from Newton, D., MRI, to Plastic Parts project file.
     February 17, 1984.  Cost effectiveness calculated for the control of
     VOC emissions from the surface coating of plastic parts used in
     business machines by thermal incineration.

14.  Telecon.  Larson, J., MRI, with Reilly, J., Electro Kinetic Systems,
     Inc.  April 25, 1986.  Discussion about coatings usage.

15.  Telecon.  Larson, J., MRI, with Keough, G., CTI/EM Lubricants, Inc.
     May 19, 1986.  Discussion about coatings usage.

16.  Telecon.  Larson, J., MRI, with Sullivan, R.,  B. F.  Goodrich.
     April 22,  1986.  Discussion about new waterborne EMI/RFI shielding
     coating.
                                  2-10

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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing!
1. REPORT NO. 2
EPA-450/3-85-0195
4. TITLE AND SUBTITLE
Surface Coating of Plastic Parts for Business
Machines-- Background Information for Promulgated
Standards
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U. S. Environmental I Protection Agency
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME AND ADDRESS
Director for Air Quality Planning and Standards
Office of Air and Radiation
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
3 RECIPIENT'S ACCESSION NO.
S REPORT DATE
December 1986
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3817
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
IS. SUPPLEMENTARY NOTES
                                                                                            of
                                                                                            I
   Standards of Performance for the  control  of VOC emissions from  affected facilities
   that perform exterior surface coating of  plastic parts for business machines are
   being promulgated under authority of Section 111 of the Clean Air Act.   These
   standards apply to each new, modified, and reconstructed spray  booth in which
   plastic parts for business machines  are surface coated and for  which construction
   commences on or after the data of proposal of the regulation.   This document
   contains a detailed summary of the public comments on the proposed standards
   (51  FR 854), responses to these comments,  and a summary of the  changes  to  the
   proposed standards.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lOENTIFIERS/OPEN ENDED TERMS
                           c. COSATI Meld/Croup
  Air Pollution
  Pollution Control
  Standard of Performance
  Exterior Surface Coating
  Business Machine
  Volatile Organic Compounds
  Plastic  Part
Air Pollution Control
13B
18. DISTRIBUTION STATEMENT
   Unlimited
                                              19. SECURITY CLASS I Tins Report/

                                              Unclassified
                           21. NO. OF PAGES
                                              20 SECURITY CLASS /This page/
                                             \ Unclassified
                             Jfi.
                           22. PRICE
EPA Form 2220-1 (Re». 4-77)
                      PR£VIOUS EDITION 'S OBSOLETE

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